Prepare for COFI now, not after it is enacted.
The Conduct of Financial Institutions Bill is set to consolidate market-conduct regulation across the financial sector under a single, activity-based FSCA licence. A transition period of about three years is expected once it is enacted. Institutions that map their activities and close conduct gaps early will carry far less regulatory risk than those that wait.
The COFI Bill was introduced to Parliament in 2026 and is not yet law. The requirements below reflect the Bill and the published market-conduct policy framework, and will be confirmed as the legislation and the FSCA conduct standards are finalised.
Our Services
At FDP Legal, we help financial institutions and financial services providers prepare for COFI in practical, prioritised steps, including:
CONDUCT READINESS ASSESSMENT
We review your governance, products, disclosures and compliance framework against the expected COFI requirements, and set out the gaps to close and the order in which to close them.
ACTIVITY MAPPING FOR LICENSING
We help you map your current activities to the proposed activity-based model, so you understand what your business will need to be authorised for under a single FSCA licence.
TREATING CUSTOMERS FAIRLY (TCF)
We help you embed the TCF outcomes across your customer-facing functions before they become legally enforceable obligations, drawing on Francien's postgraduate research on TCF and the COFI Bill.
GOVERNANCE, CULTURE AND FIT-AND-PROPER
We help strengthen board and management oversight of conduct risk, and confirm that your key persons meet, and continue to meet, the fit-and-proper requirements.
CONDUCT POLICIES AND FRAMEWORKS
We draft and review the policies COFI is expected to require, including conflicts of interest, remuneration, complaints handling and product governance.
ONGOING REGULATORY WATCH
We track the Bill and the FSCA conduct standards as they are finalised, and update your readiness plan as the detailed requirements become clear.
Our Commitment
- Clear, prioritised readiness steps mapped to your business.
- Practical guidance that keeps pace as the COFI requirements are finalised.
Not sure where your business stands on COFI?
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